Privacy Policy

Sport-Elec (NOVEKA company) respects your privacy and is committed to protecting your personal data. This document will inform you of how we handle your personal data when you visit our website (wherever you visit it from) and inform you of your privacy rights and how the law protects you.

This document is presented in point form, so you can click on the specific areas indicated below.

Please also use the Glossary to understand the meaning of certain terms used in this Privacy Notice.

1 - Important information about our company

1 - 1   Purpose of this Privacy Policy

(a) This document is intended to provide you with information about how we collect and process your personal data through your use of this website, including any data you may provide through this website when you contact us.

(b) This website is not intended for children and we do not knowingly collect data relating to children.

(c) It is important that you read this document and any other Privacy Statement or fair processing notice we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we use your data. This Privacy Notice supplements the other notices and is not intended to replace them.

1 - 2   Controller and Agent

(a) NOVEKA, company number 88936083000018 R.C.S. and with our registered office at NOVEKA, 31 rue du Val Breton, 27520 Grand-Bourgtheroulde , France, as NOVEKA/Sport-Elec, is the controller.

(b) If you have any questions about this Privacy Notice, including any request to exercise your legal rights, please send us a request

1 - 3 Changes to the Privacy Policy and your duty to inform us of changes

The French Data Protection Act was amended on 25 May 2018.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during our relationship.

1 - 4   Links to third parties

This website may include links to third party applications, websites, plugins and applications. By clicking on these links or activating these connections, it is possible that third parties may collect or share data about you. We do not control these third party applications or websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of each website you visit.

2 - The data we process about you

2 - 1    Types of data

(a) Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).

(b) We may use, store and transfer different types of personal data about you (the majority of which is provided when you register with Sport-Elec), which we have grouped as follows:

• Identity data includes first name, last name, title
• Contact data includes billing address, delivery address, e-mail address and a telephone number
• Financial data includes bank details (IBAN) for bank transfer payments, credit card data is processed by the CIC bank
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plugin types and versions, operating system, platform and other technologies on the devices you use to access this website
• Marketing and Communications Data includes your preferences for receiving marketing from us

(c) We also collect, use and share aggregated data such as statistical or demographic data for any purpose.
Aggregate data may be derived from your personal data but is not considered personal data under the law because it does not directly or indirectly reveal your identity.
For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

(d) We do not collect Special Categories of Personal Data about you (this includes details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data).
We also do not collect information about criminal convictions and offences.

(e) We do not share your data with third party marketing operations.

3 - Submitting your personal data

You can use various methods to submit data about yourself, including

3.1 Direct interactions

You may provide us with your Identity and Contact Data by filling in forms or by corresponding with us by post, telephone, chat, e-mail or otherwise.
This includes personal data that you provide when you :

(a) register on our website

(b) order from our website

(c) subscribe to our publications

(d) request to receive advertising

(e) enter a competition, promotion or survey

(f) provide us with feedback  

(g) or submit a query by sending us a request

3.2 Automated technologies or interactions

When you interact with our website at www.sport-elec.com, we may automatically collect technical data about your device, browsing actions and patterns. We collect this personal data using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites using our cookies.

3.3 Third parties or publicly available sources

We may receive personal data about you from various third parties, as described below:

(a)   technical data of the following parts:

• analytics providers such as Google and others
• advertising networks such as Google and others
• search information providers such as Google and others 
• and affiliate programs.

4 - How we use your personal data

4.1 Legal basis

(a) We will only use your personal data where we are permitted to do so by law. In most cases, we will use your personal data in the following circumstances:

(1) We need to perform the contract we are about to enter into or have entered into with you

(2) It is necessary for our (or a third party's) legitimate interests and your interests and fundamental rights do not outweigh those interests

(3) Where we need to comply with a legal or regulatory obligation

(b) As a general rule, we do not rely on consent as a lawful basis for processing your personal data, except in the context of sending direct marketing communications to third parties by email or SMS.

You have the right to withdraw your consent to marketing at any time by sending us a request

4.2 Purposes for which we will use your personal data

(a) We have set out below, in table form, a description of all the ways in which we intend to use your personal data, and the legal basis on which we do so. We have also identified our legitimate interests, if any.

(b) Please note that we may process your personal data for more than one lawful purpose depending on the specific purpose for which we use your data. Please contact us if you require details of the specific legal ground on which we are relying to process your personal data where more than one ground has been set out in the table below.

Objective/ Activity	Type of data	Base légale pour le traitement, y compris la base d'intérêt légitime
To register as a new customer/subscriber	Identity Contact	exécution d'un contrat avec vous
To process and deliver any purchase you make make through the website	Identity Contact Financial Transaction	exécution d'un contrat avec vous
To keep you informed about the use of the Application	Identity Contact Technique Usage Profile	nécessaire à nos intérêts légitimes      (tenir nos dossiers à jour et étudier comment      les clients utilisent notre service et développent nos offres)
To manage our relationship with you, which will include:→ notifying you of changes to our terms and conditions or privacy policy terms or our privacy policy→ asking you to complete a survey	Identity Contact Profile Marketing Communication	→ exécution d'un contrat avec vous→ nécessaire pour se conformer à une obligation légale→ nécessaire à nos intérêts légitimes      (tenir nos dossiers à jour et étudier comment       les clients utilisent notre service et développent nos offres)
To enable you to participate in a draw or a or a competition	Identity Contact Profile Usage Marketing Communication	→ exécution d'un contrat avec vous→ nécessaire à nos intérêts légitimes (offrir des fonctionnalités supplémentaires à nos clients)
To administer and protect our business and this website (including troubleshooting, data analysis testing, system maintenance, support, reporting and reporting and data hosting)	Identity Contact Technical	nécessaire à nos intérêts légitimes      (pour la conduite de nos activités, la fourniture       de services administratifs et informatiques, la sécurité des réseaux, la prévention de la fraude et dans le cadre d'une réorganisation d'entreprise ou de l'exercice de restructuration de groupe)→ nécessaire pour se conformer à une obligation légale
To provide you with content from the Application and relevant advertisements and to measure or understand the effectiveness of the advertising that we provide to you	Identity Contact Profile Usage Marketing Communication                                            Technical	nécessaire à nos intérêts légitimes (pour étudier comment les abonnés utilisent notre service, pour développer notre activité et pour informer notre stratégie marketing)
To use data analysis to improve our Application, offerings, marketing, subscriber/customer relationships and our experiences	Technique Use	nécessaire à nos intérêts légitimes (pour définir les types de clients pour nos différentes offres, maintenir notre Application à jour et pertinente, développer notre activité et éclairer notre stratégie marketing)
To make suggestions and recommendations on offers that may be of interest to you	Identity Contact Technique Usage Profile	nécessaire à nos intérêts légitimes (pour développer notre service et faire croître notre activité)

4.3 General marketing

We strive to provide you with choices regarding certain uses of personal data, particularly with respect to marketing and advertising. We have put in place the following personal data control mechanisms, described in paragraphs 4 - 4 / 4 - 8 :

4.4 Our promotional offers

(a) We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you (we call this marketing).

(b) You will receive advertising from us if you have subscribed to our newsletter, or if you have provided us with your details when you entered a competition or when you signed up for a promotional campaign and, in each case, you have opted out of receiving such marketing information.

4.5 Third party marketing

We will obtain your explicit consent before sharing your personal data with any company outside Sport-Elec/NOVEKA (other than service providers) for marketing purposes.

4.6 Withdrawal of membership

(a) You may ask us or third parties to stop sending you marketing messages at any time by sending us a request at any time.

(b) If you choose not to receive such marketing messages, this will not apply to the use of your personal data in communications from us about your purchases or the NOVEKA service.

4.7 Cookies

You can set your browser to reject all or some cookies, or to alert you when websites set or access cookies. If you disable or reject cookies, please note that some parts of this Application may become inaccessible or not function properly.

4.8 Change of purpose

(a) We will only use your personal data for the purpose for which you submitted it, unless we reasonably consider that we need to use it for another purpose and that this purpose is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us with a request

(b) If we need to use your personal data for an unrelated purpose, we will inform you and explain the legal basis for doing so.

(c) Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where required or permitted by law.

5 - Disclosure of personal data

5.1 We may share your personal data with the parties listed below for the purposes set out in the table in paragraph 4 above:

(a) Internal third parties as defined in the Glossary

(b) External parties as defined in the Glossary

(c) Third parties to whom we may choose to sell, transfer or merge parts of our business or assets; we may also seek to acquire or merge with other businesses; if there is a change in our business, the new owners may use your personal data in the same way as described in this Privacy Notice.

5.2 We require all third parties to respect the security of your personal data and to process it in accordance with the law

We do not use our third party service providers to use your personal data for their own purposes and we only allow them to process your personal data for specific purposes and in accordance with our instructions.

6 - International transfers

6.1   Whenever we transfer your personal data outside the EEA

We ensure that a similar level of protection is afforded by ensuring that at least one of the following safeguards is implemented:

(a) for certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection as it has in the European Union

(b) for certain service providers based in the United States, we may transfer data to them under the Privacy Shield regime (if they are part of it), which requires them to provide similar protection to personal data shared between Europe and the United States

Please contact us if you would like more information about the specific mechanism we use when transferring your personal data outside the EEA

7 - Data security

7.1 We have put in place appropriate security measures

To prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, modified or disclosed. In addition, we restrict access to your personal data to those employees, agents, contractors and other third parties who need it.
They will only process your personal data on our instructions and are subject to a duty of confidentiality.

7.2 We have put in place procedures

To deal with any suspected personal data breach and we will notify you and any applicable supervisory authority or other regulatory body of any such breach where we are legally required to do so.

8 - Data retention

8.1 We will only keep your personal data for as long as necessary

For the purposes for which you have submitted them, including for the purpose of meeting any legal, accounting or reporting requirements.

8.2 To determine the appropriate retention period for personal data

We take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the possibility of achieving those purposes by other means, as well as applicable legal requirements.

8.3 We must keep basic information about our customers

(including contact and identity data) for 6 years after they cease to be subscribers for tax and other legal purposes.

8.4 In some cases

You can ask us to delete your data: see below for more information or send us a request

8.5 In some cases, we can anonymise

your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely and without notice.

9 - Your legal rights

9.1 In some cases, you have rights

under the data protection laws with regard to your personal data. Your enquiries may relate to the different areas listed below:

• Request access to your personal data.
• Request correction of your personal data.
• Request the deletion of your personal data.
• Object to the processing of your personal data.
• Request the restriction of the processing of your personal data.
• Request the transfer of your personal data.
• Right to withdraw consent.

9.2 If you wish to exercise any of the above rights

Please send us a request

9.3 You will not have to pay any fees

To access your personal data (or to exercise any other right). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9.4 We may need to ask you for specific information

To help us confirm your identity and ensure your right to access your personal data (or to exercise any other rights). This is a security measure to ensure that personal data is not disclosed to anyone who does not have a right to receive it.

We may also contact you to request additional information about your request in order to expedite our response.

9.5 We try to respond to all legitimate requests

Within one month. Occasionally, it may take us longer than a month if your application is particularly complex or if you have made a number of applications. In this case, we will inform you and keep you informed.

10 - Glossary

10.1 Legal basis

(a)    Legitimate interest means our business interest in conducting and managing our business to enable us to provide you with the best and safest offer and experience; we ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests; we do not use your personal data for activities where our interests are outweighed by the impact it would have on you (unless we have your consent or are otherwise required or permitted by law); you can obtain further information on how we weigh our legitimate interests against any potential impact on you in relation to specific activities by sending us a request

(b)    Contract performance means processing your data where it is necessary for the performance of a contract to which you are a party or to take action at your request before entering into such a contract.

(c)    Complying with a legal or regulatory obligation means processing your personal data where necessary to comply with a legal or regulatory obligation to which we are subject.

10.2 Third Parties

(a)    Internal Third Parties

Other NOVEKA group companies based in the EEA that provide us with IT and systems administration services and marketing services.

(b)    External Third Parties

• EEA-based service providers who provide IT, hosting, payment and digital marketing services, third party logistics providers and system administration services
• Professional advisers acting as agents, including lawyers, bankers, auditors and insurers based in the EEA who provide advisory, banking, legal, insurance and accounting services
• Commissaires aux Recettes in France (or similar in other jurisdictions), supervisory authorities, regulators and other authorities acting as joint agents or controllers based in France who require the reporting of processing activities in certain circumstances.

 11 - Your legal rights

You have the right to :

• Requesting access: to your personal data (commonly known as a "data subject access request"). This allows you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
• Request a correction: of the personal data we hold about you. This allows you to have incomplete or inaccurate data we hold about you corrected, although we will need to verify the accuracy of the new data you provide.
• Request deletion: of your personal data. This allows you to ask us to delete or withdraw personal data where there is no valid reason to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we are required to delete your personal data to comply with local legislation. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Objecting to processing: of your personal data where we rely on a legitimate interest (or those of a third party) and there is something about your particular circumstances that makes it appropriate for you to object to processing on this ground, as you believe it affects your fundamental rights and freedoms. You also have the right to object to the processing of your personal data for direct marketing purposes. In some cases, we can demonstrate that we have a compelling legitimate reason to process your personal information, which overrides your rights and freedoms.
• Request restriction of processing: of your personal data. This allows you to ask us to suspend the processing of your personal data in the following scenarios:

    - (a) if you want us to establish the accuracy of the data
    - (b) where our use of the data is unlawful but you do not want us to delete it - (c) where you need us to retain the data even if we no longer need it to establish, exercise or defend legal claims
    - (d) you have objected to our use of your data but we need to check whether we have compelling legitimate reasons for using it.

• Request the transfer of: your personal data to you or a third party. We will provide your personal data in a structured, commonly used and machine-readable format to you or a third party you have chosen. Note that this right only applies to automated information for which you initially gave us your consent.